Consultation on Revising the Northern Ireland Waste Management Strategy Introduction arc21 is a collaborative legal public sector entity embracing eleven Councils located along the Eastern Region of Northern Ireland which covers 25% of the land base, populated by approximately 57% of the national population and accounts for approximately 54% of the national municipal waste ( as currently defined) arisings. The establishment of arc21 together with its functionality is enshrined in legislation with the original provision being The Local Government (Constituting a Joint Committee a Body Corporate) Order (NI) 2004. In essence, it is primarily responsible for activities associated with the production, ongoing development and implementation of a Waste Management Plan within the Eastern Region Area. The eleven constituent Councils of arc21 are Antrim Borough Council, Ards Borough Council, Ballymena Borough Council, Belfast City Council, Castlereagh Borough Council, Carrickfergus Borough Council, Down District Council, Larne Borough Council, Lisburn City Council, Newtownabbey Borough Council and North Down Borough Council. Report arc21 welcomes the opportunity to respond to this consultation. Overview The following is an overview of the arc21 comments arising from the draft Strategy document. Approach to the Strategy The aspirations of the Strategy are moving in the right direction, but more focus is needed on the development of a more holistic approach. It is critical that government sets the framework, and leads the process for Northern Ireland, within the UK, and with Republic of Ireland and Europe, rather than waiting for a lead from other bodies such as Defra. It is also critical that the department takes a holistic view of the infrastructure requirements, taking the waste hierarchy (including recycling) into account and to prepare for the expected 2025 1 landfill ban. A long-term strategic view is required, with the necessary funding made available, to provide an adequate lead-in time to 2025. As indicated above, the strategy is taking Northern Ireland in the right direction as portrayed in the prime aspiration of a strategic shift from resource management to resource efficiency. However the strategy lacks sufficient tangible measures and proposals to suggest that an adequate shift is likely to be achieved in the future. The strategy contains a number of commitments to consult on a variety of aspects but lacks an indication of meaningful detail in this respect. Even allowing for compliance with European Directives, it is suggested that a move towards resource efficiency should be marked with a move away from applying weight based targets to one which more adequately reflects a life cycle approach perhaps entailing carbon accounting. Evidence-based Policy There is a pressing need in Northern Ireland to develop a robust evidence base for our waste policies, including cost/benefit analysis for any decisions. Attention must be paid to the balance between inputs and outputs. This should be undertaken with due regard to adopting an approach which, as indicated above, more adequately reflects a life cycle approach. This Strategy represents the prime document which should enable Northern Ireland to continue towards more sustainably and efficiently utilising its waste material as a resource. The framework outlined in the document is articulated in a more local perspective through the production of Waste Management Plans by Councils through the Waste Management Groups. Consequently it is important that the Strategy clearly outlines the evidence to enable the Waste Management Plans to properly articulate the local translation of policies etc in a consistent and compatible way. As an example, there are no assumptions made in the Strategy in relation to waste growth, which will have a knock on impact on the revision of waste management plans; neither are any assumptions made in relation to export of waste. It is important that all three plans are able to work from the same basic and evidenced baseline. Finance arc21 consider that the Strategy must be adequately financed in the context of policy compliance at a European, National and Local level. We consider that it is important that the focus on infrastructure is not constrained to Residual waste landfill diversion targets at 2020 and that amore long-term approach to supporting the policy direction of travel is taken particularly in the context of subvention. Timing It is unfortunate and regrettable that the review has not been able to be undertaken before now. The timing of this Strategy revision, whilst required in legislation, is problematic in relation to the revision of waste management plans and the local government reform timetable. The inclusion of unresolved policy actions has exacerbated this issue. 2 However, arc21 remain committed to liaise with the department to address this difficulty and would urge the department to work with the Waste Management Groups in a true partnership approach. Prevention/reduction v recycling The challenges between the need to improve waste prevention/reduction and the impact this will have on weight-based targets needs to be carefully considered. The overall carbon impact of proposed policy instruments must be fully taken into account, and an agreed framework clarified for making policy decisions. Infrastructure Development Moving towards resource efficiency will necessitate infrastructure development including regionally significant facilities. The Strategy is light on the measures that will be taken by government to encourage this. The Strategy only appears to consider support for the minimum needed for Northern Ireland to meet European Landfill Diversion requirements. This approach is not compatible with resource efficiency or other overarching statutory obligations and policies. arc21 would contend that the final strategy should include proposals which clearly demonstrate support for infrastructure development which will contribute to such. Targets If the department is intent on applying a 60% target for Local Authority Collected Municipal Waste by 2020 then the proposed application and composition of this target must be clarified as a matter of urgency and priority. Given such a target is much more onerous than required in the European Directive, it is considered reasonable that Government should also be prepared to provide resources to cover or support the additional cost implications of introducing such a target. Ambiguity Any ambiguities in evidence within the document, for example in relation to separate collection, should be addressed as a matter of priority and urgency and be reflected in the final publication. Communications Further work must be done to improve communication of key messages, to improve buy-in from the public and from government departments. Consideration must be given to the application of Re:Think waste monies, and there must be work done across government to integrate front-facing waste and resource policy between departments. 3 Integration of waste streams Although the draft Strategy talks about integration of waste streams, there seems to be little within the document in relation to outcome-focused action on this issue. arc21 is concerned by the department’s current over-reliance on the marketplace in this regard. Consideration must be given to the possibilities in relation to the integration of different waste streams in Northern Ireland. This could include the introduction of measures to require the packaging and retail industry to tangibly support council collection and disposal infrastructure and services, and to facilitate and promote a greater level of collaboration between producers, retailers and collection/disposal authorities in Northern Ireland. Separate collection As previously indicated on a number of occasions, arc21 would urge the department to expedite the production of the necessary guidance etc to provide sufficient clarity in respect of the associated obligations around this issue. This relates in particular to establishing what is “technically, environmentally and economically practicable” , “necessary quality standards for the relevant recycling standard” and a Code of Practice for MRF Operators. The longer it takes to clarify such matters the greater the risk of litigious action against councils. Delivery and Governance arc21 would suggest a more effective governance monitoring model would be that similar to the independent Waste Advisory Board which operated during the first National Waste Strategy . Review of Public Administration It may be timely in the context of Local Government Reform to visit the debate on Waste Disposal Authority Models. Compliance with Waste Regulations 2011 The department must satisfy itself that the final published Strategy revision complies with the relevant obligations laid down in regulation 5 of the Waste Regulations 2011. The department may wish to consider if the strategy sufficiently covers the objectives outlined in Schedule 3, Part1, sections 2(2) and 4. In addition, there is concern that the matters laid out in Part 2 are inadequately addressed, and that there are some omissions from the Strategy as a result of this. Addressing such would benefit the development of the Waste Management Plans. 4 Detailed Comments Nowithstanding the above overview, arc21 would comment further as follows; PART 1 - SETTING THE SCENE Key Strategic Drivers The key strategic drivers of resource efficiency, sustainable development, climate change, the green economy and health